Privacy Policy

Last modified: 22 February, 2019

Persontube is an adult entertainment site, which offers live cam performances
and other related adult services.

When you use these services, you will share some personal information with us. Because we want
you to enjoy our services in a peaceful and trustworthy way, please be assured that we are fully
dedicated to the protection of your personal information.

Because your privacy is so important to us, we provide you with this Privacy Policy, explaining
how we collect, use and share your personal information, so that you can make informed choices
about the use of your data.

Please read this Privacy Policy carefully. We have tried to write it in a way, which is free of
long boring sentences and legal terms. You can contact us if you have any question about our
privacy practices or about what we are doing with your personal information. We will be happy to
provide you any assistance you may need.

Who decides "HOW" and "WHY" your personal data is processed?

The company, which decides how and why your personal data is processed, and which is called "Data
Controller" is:

Duodecad IT Services Luxembourg S.à r.l., a private limited liability company incorporated in
Luxembourg, with registered address at 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand
Duchy of Luxembourg, registered with the Luxembourg Trade and Companies Register under number
171.358.

What personal data do we process?

We collect, use, share, transfer, and store different types of your personal data as a result of
your visit of and/or use of our services on our site.

The personal data we collect includes the following categories of data:

Personal data you give to us

When you create a customer account on our site

When you create an account on our site, we require important details about you:

an email address;

a username;

a password.

In order to give yourself more visibility and presence on our site, you can complete "My Profile" in your account settings. By doing so, you are free to give to us some additional information, such as:

a nickname;

your gender;

your age;

your location;

your sexual preferences;

your interests and hobbies;

your personality traits/character.

When you contact our Billing & Customer Support

We collect all information you choose to share with our Billing & Customer Support, like:

your personal e-mail;

the services, the Model or customer username associated with your request;

your comments or opinions about a Model;

your conversations with the Support Team.

More generally, when you communicate with us in any other way, we will collect whatever information you provide us with.

When you purchase credits

When you purchase credits in order to participate on our site, depending on the
payment method you choose, we may collect and process your identification
information (first name, last name, country, ZIP code) and payment information.

Personal Information we get when you use our services

We collect certain information about you when you are using our services and navigate on our
site.

Concretely, this means that, when you visit our site or use our services, even if you have
not created an account or logged in, we collect certain information about you.

Usage information

We collect information about your activity on our site and about how you interact
with the features of our site. Basically, we know:

your activity history on our site and the special features you used on the site,
for example, if you voted in awards, sent a feedback after private chat, rated
and/or put a Model in your list of favorites, made a Video/Voice Call to the
Model, subscribed to Model’s MyStory, etc.;

the time you spend in private chat, who are the Models and categories of Models
(for example, Asian girls, Latin women, black air) you watched;

We also collect information about your communications with the Models, such as:

For technical purpose, we store on our system content you create and/or post and/or
transmit on/via our site (for example, pictures) and information about the content
you create or provide.

We also collect, any information you communicate to and/or share with Models on the
site, such as the messages you send in private chat or during live shows.

If you turn on your microphone in private chat, we may retain your audio feed for a
limited period of 6 months in order to protect our rights or defend ourselves
against any claims. Any such data retained shall be held in our secured records with
restricted access. Please note that in case you turn on your camera in private chat,
we never record or keep in any way your camera feed. We also do not allow our Models
to record or capture your personal camera or audio feeds during private shows. Such
action is prohibited on our site.

If you use the Video/Voice Call feature on our site, we do not record or process your
communication data with the Model. Your communication is private.

We collect any other communication data such as telephone conversations, chat logs,
text messages, faxes and letters you send to us.

Log data and device information

We automatically collect log data and information from or about your computer, phone,
or other device you use to access our services or navigate on our site. This
includes:

identifiers associated with cookies or other technologies that may uniquely
identify your device or browser.

If you are using a mobile device, we might also collect:

data that identifies your mobile device;

device-specific settings and characteristics;

location details;

app crashes and other system activity.

Information collected by cookies and other technologies

Like many websites and applications, we use cookies and other technologies (such as
web beacons, web storage, and unique advertising identifiers) to collect information
about your activity, browser, and device.

Most web browsers are set to accept cookies by default. If you prefer, you can
usually remove or reject browser cookies through the settings on your browser or
device. Keep in mind, though, that blocking cookies may negatively affect your use
of the services on our site. To learn more about how we use cookies and your
choices, please check out our Cookies
Policy.

Personal data we receive from third parties

We collect information that users of the site, such as Guests, Members or Models provide
about you in the course of the chat conversation or communication with our Billing and
Support Team.

The personal information we collect may also come from third parties, such as partners
and service providers, to the site. These third parties assist us in maintaining data
accuracy and providing and enhancing the services. We are also dealing with partner ad
networks, which help us to promote our site. For example, we might receive information
about your experiences and interactions from our partner ad networks.

We are also managing an ad network and promotional tools ourselves and may receive
information about your experiences and interactions with our ads and promotional tools
published/used on third party or affiliated sites.

Personal data we collect from publically available sources

We collect publically available information about you only when it is necessary to prevent
fraud and illegal activities on our site (for example, when we suspect that you are using a
false or stolen credit card, when we witness child abuse cases, or pedophile activity,
etc.).

This data may comprise publically available information you share on social media like
Facebook,
your blog and/or site, and any other public data available on the internet.

This information is always associated or combined with the data we collect through our site
in order to finalize our investigation before reporting any fraud and illegal activities to
authorities. We never use publically available data for any other purpose.

Special category of data

Persontube is an adult entertainment site and, due to the
nature of our site and its purpose, we may have data about you, which could
possibly reflect your sexual interests.

If, after creating an account, you freely indicate certain sexual preferences in
order to give yourself more visibility and presence on our site, you are providing
us with details about your sexual interests.

When you use our site, for example when you visit the pages of the Models or when you
watch live cam shows, we process and store information related to your activity
(e.g. the category of Models you watched or the page you visited) in order to
provide you with the services you requested for and enhance your experience on the
site. If you agreed to receive promotional emails from us, we will also send you
special offers and news about our features based on your interests on our site.

Due to the explicit meaning of each category name, as well as the types of Models
you request services from (e.g. Asian girls, White Ladies, Latin Women, etc…), it
is possible that the chosen categories indicate your online sexual preference to
us.

We understand that this may not explicitly reflect the reality of your life outside
of the site. Your online preferences may only be a role that you choose to play in a
virtual environment. However, in order to provide you with the highest level of data
protection, we categorize such type of data under the sensitive data category, which
is highly protected and handled with the utmost care.

What are your choices regarding the collection and use of your sensitive
data?

Because your online sexual preferences and other data relating to your sexual
interests are essential aspects of privacy, we are maintaining very high IT security
standards. We are periodically proceeding with controls and assessments of our
security measures, in order to guarantee a trustworthy environment.

We will always ask you to agree to the use of your sensitive data.

Please be aware that you can change your opinion regarding the processing of the
aforementioned sensitive data in your consent settings at any time.

However, please note that refusing to provide or revoking your consent to have this
data collected and used means that you will not be able to log into your account and
use the services, as we will not be able to provide you with the services without
processing such information.

In case you freely indicated your sexual preferences in your account settings, and you just want to delete this data, you can
easily remove it from your profile in your account. This will not affect your use of
the site.

Why do we process your personal data?

We use the information we collect for the following purposes:

Open your Member account and provide you with the services

Primarily, we use the personal data you give us when you create your account to open and
administer your online account, to allow you to do a number of activities and to use
features of our site. In addition, we use the information to allow you to purchase credits
and benefit from paying and non-paying services.

Your account is also a way to exercise control over your personal data. In your account, you
can manage your purchases, take advantage of special offers, and manage your account
settings. You are in control of what you use to complete your profile, and can choose the
information you wish to share with us.

We process this information given our legitimate interest in providing you the services you
requested and creating your account.

If you fail to provide minimum details about you, the consequence will be that we will not be
able to create an account and allow you to use our services.

Improve and promote our services

We use your personal data for analytical and statistical purposes. We place great
emphasis on the improvement of our services and on the enhancement of your
experience as a Member or Guest.

In order to better understand what your needs are and how we can improve our
services, we compile the information you gave to us or that we collected about you
when visiting pages on our site or while using our services, to detect general
trends regarding the preferences/habits of our users. This helps us to generate
statistical reports, for example, general statistics reports on our customers’
activity based on the categories of Models viewed, the countries, or the
purchases.

We are also using Hotjar in
order to better understand our users’ needs and to optimize this service and
experience. Hotjar is a technology service that helps us better understand our users
experience (e.g. how much time they spend on which pages, which links they choose to
click, what users do and don’t like, etc.) and this enables us to build and maintain
our service with user feedback. Hotjar uses cookies and other technologies to
collect data on our users’ behavior and their devices (in particular device's IP
address (captured and stored only in anonymized form), device screen size, device
type (unique device identifiers), browser information, geographic location (country
only), preferred language used to display our website). Hotjar stores this
information in a pseudonymized user profile. Neither Hotjar nor we will ever use
this information to identify individual users or to match it with further data on an
individual user. For further details, please see Hotjar’s privacy policy by clicking
on this
link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about
your usage of our site and Hotjar’s use of tracking cookies by following this
opt-out
link.

We also use your personal data for testing purposes, troubleshooting and improving the
functionality and quality of our online entertainment services. Our main goal is to
optimize our site and services to your needs, which makes them easier and more enjoyable
to use.

We share very limited characteristics about you with the Models registered on our site,
so that they can deliver a service adapted to you. Please see point "With
whom do we share your data?" to learn more.

We use limited information to tailor our services for you. For example, when you visit
and login on our site, we use your IP address to determine the country where you are
from, and display our webpages in your language, so if you visit or login on our site
from the United States, our site will automatically display content in English.

We have affiliate programs through which webmasters or other third parties can help us
to promote our sites, for example by creating reproduction of our well-known sites.
Those sites can include only certain categories of Models.
We share some limited information about you with the webmasters or other third parties
participating to our programs, in order to help them to setup, maintain and optimize
their marketing campaigns or promotional activities. This also allows them to track
their income. Please see point "With whom do we share your data?"
to learn more.

Finally, please be aware that any information that you made public on our site, such as
comments on the public wall of Models, may appear on search engines results, together
with your username.

We process this information given our legitimate interest in developing and improving our
site and our users’ experience, as well as to promote our services and our sites.

Customer relationship management and communication with you

We provide Customer and Billing Support service 24 hours a day, 7 days a week.
Sharing your personal details with our Customer and Billing Support Team allows us
to respond to any question you might have about our services.

All your communications with our Customer and Billing Support and all information you
provide in the course of such communications, including any review or opinion about
the services of a Model, are stored and reviewed so that we may respond to your
request. We can also ensure this way full compliance of all users of our site with
our terms and conditions.

Some of the recorded communications with you are used for training purposes of our
employees within the Customer and Billing Support, so that we can ensure customer
service excellence.

Finally, be aware that, when receiving a request or claim of a customer, our Customer
and Billing Support Team can access all information you give to us and all usage
information we collected about you. We want to make sure that our Customer and
Billing Support has all information needed to appropriately and immediately respond
to your request.

Please note that the Customer and Billing Support may also communicate with you
through emails or any other means, if appropriate.

Please note that we may also communicate with you through emails or any other means, if
appropriate, in order to inform you of certain changes regarding our site or of certain
events, for example, when you successfully register on our site.

We process this information given our legitimate interest in improving our users’
experience and delivering appropriate customer services to you.

Payment

Depending on the payment method you choose, we use your identification data and payment
information to process transactions.

The use of your personal information is necessary to perform the contract that you have
with us. If you purchase credits, we will use your information to execute the payment
and provide you with the services.

Ensure a safe and trustworthy environment

Because we want to create and ensure a safe environment where you can peacefully enjoy
our services, we use your personal data to detect and prevent fraud and other illegal
activities on our site.

We also use your data to detect potential breaches to the rules of our site. The rules
of the site are explained in our terms and conditions.

Finally, we use your personal information for security purposes and risk assessment,
such as to authenticate you on our site and verify your identity.

We process this information given our legitimate interest in ensuring compliance with the
rules of our site, fraud detection and prevention, as well as, information, system, network
and cyber security.

Sending of customized marketing emails

This will allow you to be informed of new services/features or special offers.

If you accepted to receive marketing emails, we will use:

the information you gave to us,

the information we get about you when navigating on our site and using our services.

Based on this information, we will send you marketing emails tailored to your tastes or
to certain of your characteristics (such as your country, the time you spend on the
site, the amount of credit purchased).

The sending of marketing emails is based on your consent. However, be aware that you can very
easily revoke such consent at any time in your “Consent Settings”. Revoking consent means
you might miss out information on new services and special offers.

If you agreed to receive marketing emails, we may pseudonymize your email address and use it
to generate statistical results. Such statistics are in the form of aggregated data and not
personal information (for example, number of users per country who are receiving marketing
communications).

Personalized content

We are using a software, which is learning about your behavior on our site (for example, when
you are navigating on our site, viewing livestreams, looking at Models’ profiles or adding
favorites to your lists) and able to predict the types of Models who could be of interest
for you.

Thus, the webpage will adapt to your needs and you will quickly find content related to your
preferences.

Whether you created an account or not, the software will display, at your next login or
visit, a webpage based on your preferences from previous activity.

We rely on your consent to create a customized experience for you.

You may withdraw your consent at any time by opting-out in your Consent Settings or via email
in case you are not a Member yet. Revoking your consent to content personalization may
negatively affect your experience.

Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data. For example, we retain your
transaction information to maintain legally required accounting records.

We may also use your information to respond to requests of competent authorities or given our
legitimate interest to establish, exercise or defend legal claims. We also use your data, if
necessary, to investigate issues with the bank processing your payment or with a debt
collector, in case of unpaid transactions, chargebacks or refunds.

We may combine your information with information lawfully obtained from other third party
sources and use it for the above purposes.

We actively implement data loss prevention systems against leakage, theft and data breach in
order to ensure that our site and the entire IT infrastructure related to it are updated against
the latest network security vulnerabilities. We periodically test our IT systems and do
sophisticated penetration tests. Our site incorporates the most advanced security technologies
available in order to ensure maximum safety of its users and the safekeeping of their related
information.

We will retain your personal data for as long as we consider it necessary to:

Enable you to use our services and provide our services to you, including maintaining your
customer account;

Comply with our legal obligations. For example, we may keep some of your information for
tax, legal reporting and auditing obligations. Please note that, according to Luxembourg
legislation, financial related information shall be kept for a period of ten years.

Conduct our business and for our legitimate business interests, such as establishing,
exercising or defending legal claims, chargeback prevention, fraud detection and prevention,
hindering any other illegal activity on our site, and enhancing safety. For example, if we
close or suspend your account for fraud or illegal activities, we may retain certain
information about you to prevent you from opening a new account in the future. Such
information shall also be kept available in case of ongoing judicial proceedings/and or
investigations. As part of our fraud detection and prevention process, we also blacklist all
former usernames for a certain time. Therefore, a former username cannot be used for a new
registration.

Protect our site and your personal information from accidental or malicious loss and
destruction. Residual copies of your personal information may not be removed from our backup
systems for a very limited time (usually 30 days).

Some copies of your information (e.g., log records) may also remain in our database, but are
disassociated from personal identifiers.

In case you have a question about a specific retention period for certain categories of personal
data we process about you, please contact us via the contact details provided in point "How to contact us?"

With whom do we share your data?

We share certain of your personal data with the following parties:

With the Models

Your contract with us secures your ability to benefit from and purchase services relating to
adult entertainment from Models.

Regarding your profile information, by default, the only data element visible to the
Model is your username.

However, you may choose to share with a Model other information about you that you
added to "My Profile" in your account settings, like your gender, age, location,
interests, etc…; you may also connect your camera in private chat in order to
visually communicate with the Model or just turn on your microphone. The Model is
not allowed to record the visuals you provide.

In any case, please keep in mind that you can manage the visibility of the
information you added in "My Profile" by selecting the appropriate option in your
privacy settings and therefore decide who can see the information you put on your
profile.

In case you decide to share additional content with the Models, such as pictures,
please note that you are fully responsible of such sharing of information and that
we cannot be held responsible of any disclosure you freely made.

What else do we show about you to the Models?

As the Models are appearing on several sites at the same time (all our sites and
affiliated sites), we show them from which site you are visiting from;

We show them a special icon, if you subscribed to their fan club;

We show them a special icon, if you added them in your favorites;

We show them a special icon, if you are a regular Member on a site and already
purchased a certain number of credits, so that they know that you deserve extra
attention and a good service. Please be aware that you can deactivate this
feature, by contacting us to the email address or address indicated in point "How to contact us?".

With other users of the site and with the public

When you chat with a Model in a free chat, other users of our site can see your username
and the messages you write. In addition, other users can see in a free chat if you
become a King of the Room and the number of credits you spent on surprises for said
purpose.

If you added information about yourself to “My Profile”, you may choose to disclose such
information to other users, only to Models with whom you are in private chat or with no
one, in your privacy settings. As indicated, please keep in mind that you can manage the
visibility of the information you added in “My Profile” by selecting the appropriate
option in your privacy settings and therefore decide who can see the information you put
on your profile.

In addition, if you post comments on a Model’s wall, other users will see your comments.
Your comments and username may also be visible on the results of a search engine, like
Google, for example. Therefore, if you do not want other users or the public in
general to see your comments, please do not post comments on a Model’s
wall.

When you initiate a private chat with a Model, apart from the Model, only limited staff
within our organization can access on a "need to know" basis the communications and/or
images (in case you turn on your webcam) you share. Be assured that other Guests or Members
of Persontube will not access any information about you from the moment you
enter into a private chat.

Entities of our company’s group

We share your personal information with the following companies of our group based in
Luxembourg, Hungary, and the US, as they are helping us to deliver the services to you:

Webmasters participating to our affiliate programs

We have affiliate programs through which webmasters and other third parties can help
us to promote our sites, for example, by creating reproduction of our well-known
sites. Those sites can include only certain categories of Models.

Please be aware that by registering on one of our affiliated sites, you will also be
considered as registered on our original sites, including notably
livejasmin.com and jasmin.com. You can therefore log in on these different sites with the same login
credentials.

Please note that, whether you registered directly on one of our sites or on one of
our affiliated sites, we stay the controller of your personal data. For example,
when you create an account or purchase credits, the personal information that you
give for these purposes goes directly to us. The webmaster cannot see or access your
personal data, and is only a technical operator and business partner helping us to
promote our activity. In no event, you are a client/customer of a webmaster.

We only share some limited information with them that however cannot lead to your
direct identification. This minimum information helps them to setup, maintain and
optimize their marketing campaigns or promotional activities. This also allows them
to track their income. This information consists in your registration date, the site
where you come from, register or purchase credits, your country, your username, the
packages of credits bought (in case the webmaster was eligible for a commission) and
certain device information (your operating system, your browser type and the type of
device (e.g. tablet, mobile, desktop)).

Please be aware that we will never share with them any information leading to your
direct identification, for example, your real name, your address, your email
address, your payment details or your IP address.

Service providers

We use carefully selected and trusted third parties, who act as service providers to our
site.

We ensure that they are bound by contractually binding obligations to process information we
share with them in accordance with our instructions, this Privacy Policy and all applicable
data protection laws.

As we constantly work on the development and enhancement of the technology to support our
site, our third party service providers we are using may regularly change. Such entities
mainly belong to the following areas: (a) business intelligence and analytics; (b) customer
care; (c) marketing and sales; (d) fraud prevention.

Payment providers and financial institutions

When you purchase credits, depending on the payment method you choose, your payment may be
processed by a third party bank or payment processor and you may share with this party
certain details, as well as payment information for the purpose of completing a
transaction.

You may receive transactional emails from this party confirming the order, including
dispatch, possible refunds, and follow-up invitations to leave feedback for this party.

If you share information with third parties directly, this Privacy Policy does not govern the
processing of your personal information by these third parties.

If you choose the payment method “Credit/Debit card”, your transaction will be handled by
Escalion S.à r.l., which is part of our companies group and located in Luxembourg. For your
information, you can find its privacy policy here.

When a chargeback is requested by you or by the holder of the credit card used to make the
transaction, we have, in certain cases, to share some information about you and your use of
the services with the processing bank.

We may furthermore share information with relevant financial institutions, if we consider it
strictly necessary for fraud detection and prevention purposes.

Law enforcement agencies or governmental authorities

To the extent permitted by applicable laws, we may also share information with law
enforcement agencies or authorities, if such disclosure is reasonably necessary to (a)
comply with our legal obligations, (b) respond to information requests for fraud
investigations and alleged illegal activities, (c) enforce and administer our terms and
conditions, and/or (d) protect our rights or defend ourselves against any claims.

Business transfers

Finally, please also note that your information may be transferred to another entity of our
group following some internal reorganization or to another third party entity in case of
sale, reorganization, restructuring, merger and/or acquisition or any other disposal
whatsoever at group or company level resulting that part (more than 50%) or whole of our
business (or related assets) is either directly or indirectly transferred or falling under
control of a third party acquirer, provided the latter and/or the other group company in
case of internal reorganization operates within same or similar line of business as ours and
commits to comply with this Privacy Policy.

How do we transfer your personal data outside of the European Economic
Area?

In the course of the operation and exploitation of the site and the provision of the services,
your personal information may be transferred outside of the European Economic Area ("EEA") to
our affiliated companies or to third parties data processors located in the US and other
countries outside of where you live, for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and
freedoms in respect of the processing of your personal data are adequately and appropriately
protected. For this purpose, we utilize the Standard Contractual Clauses approved by the
European Commission that you can find here.

What are your rights regarding your personal data?

We did our best to explain what your rights are and how you can exercise them. If, despite of our
below explanations, you are still unsure about the actions you can take or the conditions of
exercise of your rights, do not worry, our Support Team will provide you with all the assistance
you need when exercising your rights.
You may also contact us, at any time, before exercising any of your rights, and we will reply to
your request as quickly as possible.

Please note that we created a specific interface called "Privacy Rights" in your account settings
in order for you to be able to easily exercise certain of your rights.

Our Support Team will provide you with information on actions taken within one month of the day
of receipt of your request. Only in exceptional circumstances, when we face complex and a high
number of requests, we may extend this period of response up to two further months.

Please note that rights may be exercised free of charge. However, unfounded or excessive
requests, in particular because of their repetitive character, will lead to the payment of a
fee.

Please also understand that, because your privacy is so important for us, our Support Team may
need to duly verify your identity and ask you to provide additional information before executing
your request.

Data access and data portability

You have the right to access the personal information that we hold about you by requesting a
copy of your personal data free of charge through the "Data Download" section in your
account settings.

Upon verification of your identity, your request will be sent to our Support Team.

If we consider that your request is manifestly unfounded or excessive (for example, because
you requested a copy of your data numerous times in a short period of time), we may refuse
to act or charge a reasonable fee taking into account the administrative costs for providing
you the information.

In certain cases, you may also be entitled to request copies of personal information that you
have provided to us in a structured, commonly used, and machine-readable format and/or
request us to transmit this information to another service provider (where technically
feasible). For this purpose, you can send an email to privacy@dditservices.com.

Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

Data retention and erasure

If you no longer want us to use your information, you can request that we erase your personal
information and close your account. Request for account cancellation or closure will
be considered as a request for erasure of your personal data. In such case,
please select “Forget my Data” in the "Privacy Rights" section of your account settings.

Your request will be sent to our Support Team who will contact you to learn more about your
request. However, if you face any difficulties, please contact us at any time.

Please note that if you request the erasure of your personal information, we will retain your
personal data for as long as we consider it necessary to:

Comply with our legal obligations. For example, we may keep some of your information for
tax, legal reporting and auditing obligations. Please note that according to Luxembourg
legislation financial related information shall be kept for a period of ten years.

Conduct our business and for our legitimate business interests, such as establishing,
exercising or defending legal claims, chargeback prevention, fraud detection and
prevention, hindering any other illegal activity on our site, and enhancing safety. For
example, if we close or suspend your account for fraud or illegal activities, we may
retain certain information about you to prevent you from opening a new account in the
future. Such information shall also be kept available in case of ongoing judicial
proceedings/and or investigations. As part of our fraud detection and prevention
process, we also blacklist all former usernames for a certain time. Therefore, a former
username cannot be used for a new registration.

Protect our site and your personal information from accidental or malicious loss and
destruction. Residual copies of your personal information may not be removed from our
backup systems for a very limited time (usually 30 days).

Some copies of your information (e.g., log records) may also remain in our database, but are
disassociated from personal identifiers.

Right to object

We process your data for a variety of reasons as explained in "Why
do we process your personal data?". Applicable law may entitle you to
require us not to process your personal information for certain specific purposes
where such processing is based on legitimate interest. If you object to such
processing we will stop processing your personal data for these purposes.

In specific situations, we may have to refuse the execution of your request. This
would be the case where we have legitimate grounds to continue such processing or if
we have to establish, exercise or defend legal claims.

Please keep in mind that objecting to the use of your data might disable the use of
your account.

Please note that you may, at any time, ask us to stop sending you marketing emails by
opting-out in your account settings.

Right to restriction of processing

You have the right to request that we hold your personal data in "limbo", while other
challenges are resolved.

Basically, you can ask us to put on hold the use of your data in 4 cases:

If you contest the fact that the personal data we hold about you is accurate: in this
case, the processing operations in relation to this data will be put on hold for the
period during which this is verified.

You have objected to a processing activity based on legitimate interest(s): in this
case, you can require the processing operation to be put on hold while we verify the
grounds for processing.

You consider that the processing is unlawful but you object to erasure and request
restriction, instead.

We have no further need for the data but you require it to establish, exercise, or
defend legal claims.

Despite your request, we may still continue the processing of your personal data if we have
to establish, exercise, or defend legal claims. We will notify you before lifting a
restriction.

Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other
applicable national laws, you have the right to lodge a complaint with a supervisory
authority, (in particular in the Member State where you live, place of work or of an alleged
infringement of the GDPR).

Changes to our Privacy Policy

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we
handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on the
relevant site and/or contact you using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are
published on our site, unless we specify a date of entry into force. Your continued use of our
site from that day on will be subject to the new Privacy Policy.

How to contact us?

If you have any comments or questions about this privacy policy or generally about our privacy
practices, please send an email to privacy@dditservices.com
or via mail to the address indicated below, and we will get quickly back to you. We are always
glad to talk about our privacy practices.

We are also happy to inform you that we have an employee dedicated to ensuring your privacy, our
Data Protection Officer. You can directly reach our Data Protection Officer via email at: dpo@dditservices.com or mail to the following
address:

To the attention of the DPO
Duodecad IT Services Luxembourg S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg